Overview
- Headquarters
- Cincinnati, OH
- Total Firm Assets
- $21.0 billion
- Average High-Net-Worth Client Portfolio Size
- $9.0 million
Recent Rankings
Fee Structure
Primary Fee Schedule (BAHL & GAYNOR ADV PART 2A 7/2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.85% |
| $3,000,001 | $5,000,000 | 0.65% |
| $5,000,001 | and above | 0.50% |
Minimum Annual Fee: $10,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $265,000 | 0.53% |
| $100 million | $515,000 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 33.36%
- Number of High-Net-Worth Clients
- 779
- Total Client Accounts
- 3,251
- Discretionary Accounts
- 3,213
- Non-Discretionary Accounts
- 38
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 106139
Additional Brochure: BAHL & GAYNOR ADV PART 2A 7/2026 (2026-07-07)
View Document Text
Part 2A of Form ADV: Firm Brochure
255 East Fifth Street
Suite 2700
Cincinnati, OH 45202
Telephone: 513-287-6100
Email: info@bahl-gaynor.com
Web Address: www.bahl-gaynor.com
7/7/2026
This brochure provides information about the qualifications and business practices of Bahl &
Gaynor LLC. If you have any questions, please contact us at 513-287-6100 or info@bahl-
gaynor.com.
The United States Securities and Exchange Commission (SEC) and state securities authority
have not approved or verified the information in this brochure.
Bahl & Gaynor LLC is a registered investment adviser under the U.S. Investment Adviser Act of
1940, as amended. Registration does not imply any particular level of skill or training. We
encourage you to carefully review both our written and oral communications in deciding
whether to work with us.
Additional information about Bahl & Gaynor LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. under our CRD number is 106139.
Item 2 Material Changes
November 2025 – Enhancements to SMA/Wrap Program Disclosures and Pricing of
Securities
• Expanded disclosures throughout the brochure to provide additional clarity regarding
Bahl & Gaynor’s role in wrap fee and dual contract Separately Managed Account (SMA)
programs, particularly in relation to Platform Partners.
• Added new language in Item 5 regarding the valuation methodology for alternative
funds, including the use of the most recent reported market value, which may be subject
to delayed reporting.
• Made additional minor edits throughout the brochure to improve clarity, readability, and
consistency. These changes do not reflect material alterations to our business
practices.
February 2026 – Annual Update, Trading Practices, and Leadership Title Changes
• Completed the annual update to the Form ADV Part 2A.
• Updated leadership titles to reflect current roles and responsibilities. These updates do
not reflect changes to ownership, management structure, or business practices.
• Updated Item 12 to provide additional disclosure regarding block trading practices,
including circumstances in which trades may be executed on a non-aggregated basis
to limit or avoid custodial transaction charges. These updates are intended to provide
greater transparency and do not represent a material change to the firm’s trading
philosophy.
July 2026 – Corporate Reorganization and Name Change
• Effective July 2026, the legal name of the registered investment adviser changed from
Bahl & Gaynor, Inc. to Bahl & Gaynor LLC.
• As part of an internal corporate reorganization, ownership of Bahl & Gaynor LLC was
transferred to Bahl & Gaynor Holdings Inc., a newly formed holding company owned by
the same shareholders who previously owned Bahl & Gaynor, Inc.
• This reorganization was administrative in nature and did not result in a change to the
team, client
investment philosophy, advisory services, management
firm's
relationships, fee schedules, or day-to-day business operations.
• References throughout this brochure have been updated to reflect the firm's new legal
name and ownership structure. No action is required by clients as a result of these
changes.
If you have any questions about these updates, please contact us at 513-287-6100 or
info@bahl-gaynor.com.
2
Item 3 Table of Contents
Item 2 Material Changes ....................................................................................................................... 2
Item 3 Table of Contents ...................................................................................................................... 3
Item 4 Advisory Business ..................................................................................................................... 5
....................................................................................................... 5
4.a. MANAGEMENT SERVICES
............................................................................................ 9
4. b. ASSETS UNDER MANAGEMENT
Item 5 Fees and Compensation ........................................................................................................... 9
....................................................................................... 11
Limited Negotiability of Advisory Fees
....................................................................................................... 11
5. a. PRICING OF SECURITIES
...................................................................................................... 12
5. b. GENERAL INFORMATION
................... 12
Termination of the Advisory Relationship for Individually Managed accounts
............................................................................................................................ 12
Mutual Fund Fees
................................................ 12
Wrap Fee Programs and Separately Managed Account Fees
................................................................................................................... 12
Retirement Account(s)
..................................................................................................... 13
Additional Fees and Expenses
............................................................................................................... 13
Advisory Fees in General
Item 6 Performance-Based Fees and Side-By-Side Management ............................................... 13
Item 7 Types of Clients ....................................................................................................................... 13
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 13
........................................... 13
8. a. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
......................................................................................................................... 15
8. b. RISK OF LOSS
Item 9 Disciplinary Information ......................................................................................................... 16
Item 10 Other Financial Industry Activities and Affiliations ........................................................... 16
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17
................................................................................................................. 17
11. a. CODE OF ETHICS
.......................................................................................................... 17
11. b. PERSONAL TRADING
........................................ 18
11. c. TRADING OF BAHL & GAYNOR PROPRIETARY ACCOUNTS
............................................................................................................................ 18
11. d. SERVING AS OFFICER, TRUSTEE AND/OR DIRECTORS OF OUTSIDE
ORGANIZATIONS
................................................ 19
11. e. RELATED PERSONS AT BROKERS AND CUSTODIANS
.............................................................................................. 19
11. f. POLITICAL CONTRIBUTIONS
Item 12 Brokerage Practices ............................................................................................................... 19
................................................................................................................. 19
12. a. BEST EXECUTION
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.................................................................................................................... 20
12. b. BLOCK TRADES
........................................................................................................................ 20
12. c. SOFT DOLLARS
.................................................................................................. 21
12.d. TRADE ORDER ROTATION
.................................................................................. 22
12. e. CROSS TRANSACTIONS (AGENCY)
Item 13 Review of Accounts ................................................................................................................ 22
................................................................................................................................ 22
13. a. REVIEWS
............................................................................................................................... 22
13. b. REPORTS
Item 14 Client Referrals and Other Compensation .......................................................................... 22
Item 15 Custody..................................................................................................................................... 23
Item 16 Investment Discretion ............................................................................................................ 23
Item 17 Voting Client Securities .......................................................................................................... 24
Item 18 Financial Information .............................................................................................................. 24
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Item 4 Advisory Business
Bahl & Gaynor LLC ("B&G") is a wholly owned subsidiary of Bahl & Gaynor Holdings Inc., an Ohio
corporation. B&G is an SEC-registered investment adviser headquartered in Cincinnati, Ohio.
The firm was founded in 1990 and also conducts business under the name Bahl & Gaynor
Investment Counsel.
Leadership Team
The following individuals serve as board members and executive officers of the firm:
Charles A. Pettengill, Director
Edward A. Woods, Director, Secretary
John B. Schmitz, Director, Treasurer
Ellis D. Hummel, Director
W. Jeff Bahl, Chairman of the Board, Director
Robert S. Groenke, Chief Executive Officer & President
Kevin T. Gade, Chief Operating Officer
Peter M. Kwiatkowski. Chief Investment Officer
Tita A. Rogers, Chief Compliance Officer
Jenelle M. Armstrong, Chief Administrative Officer
Eric M. Aber, Chief Technology Officer
Stephanie S. Thomas, Institutional Client Managing Director
Nicholas W. Puncer, Institutional Product Managing Director
Peter G. Knipe, Managing Director
John P. Galvin, Sr., Managing Director
B&G provides a range of advisory services to clients, as outlined in the sections below.
4.a. MANAGEMENT SERVICES
Bahl & Gaynor LLC ("B&G"), provides investment advisory services to a broad range of clients
including individual and institutional clients, including open-end registered funds under the
Investment Company Act of 1940, as amended (the “1940 Act”).
We also manage investments for institutions through separate accounts. These may be direct
advisory relationships or sub-advisory arrangements where we manage assets on behalf of
another adviser.
In addition, we provide investment management through programs sponsored by broker-
dealers and other financial firms. These programs may be “wrap fee” or “dual contract”
arrangements. We refer to these as separately managed accounts, or “SMA Accounts.”
Most of our services are discretionary, meaning we make investment decisions and trades for
clients without prior approval each time. In some cases, we provide non-discretionary or model
portfolio services, where clients or another adviser make the final investment decisions.
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Within B&G’s Portfolio Management business, B&G provides investment advisory and portfolio
management services for both individual and institutional clients that are individual managed.
The Portfolio Managers work with clients to determine an appropriate asset allocation and
portfolio strategy through meetings and ongoing discussions. Depending on the client
circumstances, portfolios may include:
•
Individually managed accounts – tailored to the client’s specific goals and restrictions,
or
• Model portfolios accounts – aligned with established investment strategies designed
to meet common client objectives.
Clients retain ownership of the securities in their accounts and may request reasonable
restrictions on investments on individually managed or model portfolio accounts.
We currently offer the following model strategies:
Dividend Strategy: a large cap dividend growth strategy focused on delivering long-term
growth of dividend income, downside protection, and total return.
Small Cap Dividend Strategy: a small cap dividend growth strategy focused on delivering
long-term growth of dividend income, downside protection, and total return.
Income Growth Strategy: a large cap dividend growth strategy focused on delivering high
current and consistently growing portfolio
income, downside protection, and price
appreciation.
smig® Small/Mid Cap Income Growth Strategy: a small and mid cap dividend growth strategy
focused on delivering high current and consistently growing portfolio income, downside
protection, and price appreciation.
As part of our process, B&G incorporates financial planning elements to align your portfolio
with your overall financial objectives. We gather information about your financial status, tax
considerations, goals, and risk tolerance through interviews and/or questionnaires. This
information is integrated into your portfolio strategy.
Important Note: While financial planning is part of the portfolio management process, B&G
does not provide tax, insurance, or legal advice. Clients should consult qualified professionals
for these services.
In certain cases, B&G may engage a Sub-Adviser to manage assets, primarily in tax-exempt
municipal securities. B&G retains discretionary authority to hire or terminate the sub-adviser
and reallocate assets among them.
Within B&G’s institutional business we offer advisory services within discretionary, non-
discretionary and model portfolio accounts.
B&G provides investment management services through Separately Managed Account
(SMA) programs. These programs may be offered as wrap fee or dual contract arrangements.
6
In a wrap fee program, B&G provides investment management under an agreement with the
program sponsor. The sponsor typically bundles several services—such as custody, financial
advice, and trading—into one all-inclusive “wrap” fee.
In a dual contract program, clients sign a direct advisory agreement with B&G and separately
arrange other services (like custody, financial advice, or trading) through their chosen
providers. These services may be bundled together or billed separately, depending on the
arrangement.
Clients usually select B&G, with help from the program sponsor, to manage all or part of their
account using one of our investment strategies. We manage accounts based on the
information we receive from clients and sponsors and make ourselves available for reasonable
communication requests. Some SMA accounts also receive administrative support from B&G.
Once we have reviewed the account paperwork, accepted the appointment, and received the
client’s assets, we begin managing the portfolio as soon as possible. Timing can vary
depending on how quickly the sponsor or other service providers complete their part of the
process. In most cases, clients authorize their custodian to automatically invest any cash in a
money market fund selected by the client or their advisor.
If clients or their financial advisors, ask us to execute trades for tax reasons—such as realizing
gains or losses—we will generally follow their instructions within certain limits. These decisions
can affect performance, and clients should discuss potential tax implications with their tax
professional before proceeding. B&G may also invest in exchange-traded funds (ETFs) during
these periods, and clients will bear their proportionate share of ETF expenses.
At times, B&G may provide reports or materials to program sponsors or other financial
intermediaries that use our strategies. These reports are informational only and not intended
as personalized investment advice or recommendations.
B&G also works with certain financial institutions—like banks, broker-dealers, and other
advisory firms—to provide non-discretionary investment services and model portfolios for
various strategies. These models are based on the same investment approaches we use in our
discretionary accounts.
Because sponsors or overlay managers implement trades themselves, timing differences can
occur. This means the prices they receive may be higher or lower than those obtained for B&G’s
discretionary clients, depending on the market. B&G does not control when or how these trades
are executed and cannot manage their market impact.
In model-based programs, the sponsor or overlay manager is responsible for making
investment decisions and performing many of the day-to-day functions that B&G typically
handles in a discretionary account. Depending on the program structure, B&G may not have a
direct advisory relationship with individual clients. In those cases, this brochure is provided for
informational purposes only. Performance information from B&G’s discretionary accounts may
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not reflect the experience of model-based program clients, and B&G is not responsible for the
services provided by the sponsor.
B&G provides investment advisory services to several funds, including open-end mutual fund
and exchange-traded funds (“ETFs”) registered under the Investment Company Act of 1940
(the “1940 Act”).
In connection with its advisory services, B&G generally receives either a unitary (or unified
management) fee for ETFs or an advisory fee for mutual funds. Clients should review each
fund’s prospectus, statement of additional information (SAI), or other offering materials for
more detailed information about the fund and the fees paid to B&G.
B&G serves as the adviser to the following ETFs and receives the corresponding unitary
management fee:
ETF Name
Unitary Fee
Bahl & Gaynor Income Growth ETF (BGIG)
0.45%
Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG) 0.60%
Bahl & Gaynor Dividend ETF (BGDV)
0.45%
Bahl & Gaynor Small Cap Dividend ETF (SCDV)
0.70%
When B&G exercises discretionary authority over a Fund’s assets, it does so in a manner
consistent with the Fund’s investment objectives, strategies, and limitations as described in its
prospectus or other disclosure documents. B&G’s discretion is also subject to the oversight of
the Fund’s governing body (for example, its board of directors or trustees).
For each ETF, B&G arranges for transfer agency, custody, administration, distribution, and
related services. The ETFs pay B&G a unified management fee for these services, which is
calculated daily and paid monthly.
Clients can obtain additional information about the ETFs by contacting:
U.S. Bank Global Fund Services
P.O. Box 701
Milwaukee, WI 53201-0701
Phone: 1-855-994-1711
B&G also serves as the adviser to the Bahl & Gaynor Income Growth Fund, a mutual fund. B&G
provides investment management, portfolio selection, and transaction supervision for this
Fund. For these services, B&G receives an annual advisory fee of 0.45% of the Fund’s average
daily net assets.
8
The Fund’s prospectus and SAI provide additional details about the fees paid to B&G and to
other service providers.
Clients can obtain additional information about the Bahl & Gaynor Income Growth Fund by
contacting:
Bahl & Gaynor Funds c/o UMB Fund Services, Inc.
235 W. Galena Street
Milwaukee, WI 53212
Phone: 1-833-472-2140
Although our primary strategy is dividend-growth equity, we may also invest in other vehicles
when appropriate to client objectives. These may include fixed income/credit, options, real
estate, limited partnerships, exchange-traded funds, and alternatives.
All investments involve risk, and portfolios will vary based on individual client circumstances.
4. b. ASSETS UNDER MANAGEMENT
As of December 31, 2025, we were actively managing $20,680,684,710 of clients' assets on a
discretionary basis and $309,902,397 on a non-discretionary basis. In addition, the firm
oversaw $33,960,529,926 in client assets through Separately Managed Accounts (SMA).
Item 5 Fees and Compensation
Generally, B&G’s advisory fees are based on a percentage of assets under management. Fees
and services may be negotiable based on factors such as client type, asset class, pre-existing
relationship, portfolio complexity and account size or other special circumstances or
requirements. Some existing clients pay higher or lower fees than new clients. Related
accounts may be aggregated for fee calculation purposes in certain circumstances.
When B&G calculates fees, valuations of account assets are determined in accordance with
B&G’s valuation procedures, which generally rely on third party pricing services.
Individually managed accounts are charged an annual fee paid quarterly for portfolio
management services. The fee is calculated as a percentage of the client’s assets under
management and varies based on the investment strategy.
The following schedule represents the standard fee schedule for High Net Worth (HNW) clients
and institutional clients that are individually managed utilizing Bahl & Gaynor’s Separately
Managed Accounts strategies:
Assets Under Management
1% on first $1 million
.85% on next $2 million
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.65% on next $2 million
.5% on amounts over $5 million
B&G's minimum account fee is $10,000 which may, at the firm’s discretion, be waived or
discounted.
B&G does not impose a minimum account size requirement for individually managed services.
B&G reserves the right to determine whether to accept an account based on the client’s
circumstances and the nature of the requested services. Fee calculations include cash
balances held in the account, including margin balances, unless explicitly excluded in the
Investment Advisory Agreement.
B&G generally charges advisory fees on a quarterly basis, unless otherwise agreed upon by the
client and B&G. Fees are based on the market value of the assets in the account as of the
valuation date, the average market value of the account during the billing period, or the market
value at the end of the calendar quarter, as specified in the client agreement.
Clients may authorize B&G to deduct fees directly from their custodial accounts; otherwise,
clients are responsible for paying fees directly.
Clients who engage Sub-Advisers for their fixed income assets authorize B&G to pay the sub-
adviser for its services on a quarterly basis, equal to a percentage of the fair market value of
the assets in the accounts. The value of the accounts will include accrued interest income. The
fee is charged to each account on a prorated basis upon inception of the account and at the
beginning of each calendar quarter, thereafter, based on the portfolio value as determined by
the custodian as of the last business day of the previous calendar quarter. The sub-adviser
receives an annual rate of 0.30% for aggregate accounts size of under $200 million, and 0.25%
for aggregate accounts sizes over $200 million.
Clients who invest in the Bahl & Gaynor Income Growth Fund Mutual Fund will have those
assets excluded from account-level management fees.
B&G may, from time to time, recommend that a client invest in the Bahl & Gaynor Income Growth
ETF (BGIG), Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG), Bahl & Gaynor Dividend
ETF (BGDV), and/or Bahl & Gaynor Small Cap Dividend ETF (SCDV) (collectively, the “Bahl &
Gaynor ETFs”). A conflict of interest arises because B&G receives both fund-level and
account-level fees. To address this conflict, B&G will resolve the conflict by crediting against
the account level fee an estimate of the investment management fees it receives from the ETF
(but not exceeding the full account level fee) for the period per the client’s stated fee schedule
above. This reduction is not at the combined and pro-rated relationship level.
B&G calculates fees for assets invested in Alternative Funds based on the most recent
reported market value, which is typically subject to a delayed reporting period. Fees are paid
quarterly, in arrears, based on the reported market value as of the last day of the month prior
to billing. In addition to B&G’s fees, the client will incur charges imposed directly at the fund
level (e.g., management fees and other fund expenses).
10
In the event a client account holds ERISA plan assets or assets of an IRA or other account
subject to Section 4975 of the Internal Revenue Code, B&G also complies with requirements of
Prohibited Transaction Exemption 77-4.
B&G serves as an investment adviser for separately managed account (“SMA”) programs
offered through both wrap fee and dual contract arrangements. B&G’s advisory fee for these
programs is established by agreement between B&G and the program sponsor.
For wrap fee programs, clients pay a single fee to the program sponsor that typically covers
investment management, trading, custody, and other administrative services. B&G does not
have visibility into the specific fee arrangement between the sponsor and the client or how the
wrap fee is allocated between the parties.
For dual contract programs, B&G and the program sponsor each charge their fees separately.
The advisory fee charged by B&G is agreed upon directly with the client and follows the same
guidelines that apply to B&G’s other individually managed accounts.
For Institutional Separate Accounts and dual contract SMA accounts, the timing of payments—
whether billed in advance based on anticipated advisory services for the upcoming quarter or
in arrears after services are provided—and the billing method (such as invoicing or direct
deduction of fees) are agreed upon between B&G and the client.
For wrap fee SMA accounts and certain dual contract SMA accounts, payment arrangements
are typically determined by the program sponsor. In most wrap programs, the sponsor collects
the total wrap fee from the client and remits B&G’s portion to B&G. In some dual contract
programs, the sponsor may also collect and remit B&G’s advisory fee separately.
If an account is opened or closed during a billing period, the advisory fee is generally prorated
for the portion of the period the account was active.
Limited Negotiability of Advisory Fees: Although B&G maintains the standard fee schedules,
the firm retains sole discretion to negotiate fees on a client-by-client basis for all investment
strategies. The specific annual fee schedule is set forth in the contract between the adviser
and each client.
5. a. PRICING OF SECURITIES
The majority of client assts, including equity and fixed income securities, are priced at least
monthly by an independent pricing service. From time to time certain securities may not
receive a price from the service. In such cases, it is B&G's policy to obtain the most reliable
price available from other sources. As a result, the value of these securities may at times be
overstated or understated in the month end valuation.
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Alternative funds are valued based on the most recent reportable market value. These values
are typically subject to delayed and non-standardized reporting periods and are provided to
Bahl & Gaynor directly by the fund.
While B&G seeks to exercise reasonable care in determining accurate values, this process
presents a potential conflict of interest because valuation may result in higher advisory fees.
5. b. GENERAL INFORMATION
Termination of the Advisory Relationship for Individually Managed accounts: B&G generally
charges advisory fees either in arrears or in advance, depending on the client relationship. For
certain accounts, fees are billed quarterly in advance, based on the anticipated advisory
services for the upcoming period.
In the event of termination mid-period, clients receive a rebate of any unearned portion of
prepaid fees. B&G calculates the earned portion of the fee through the termination date and
refunds the remaining unearned portion either directly to the client or to the custodial account
from which the fee was originally deducted.
Mutual Fund Fees: Client portfolios may, from time to time, be invested in mutual funds, index
funds, and/or exchange-traded funds (ETFs). These vehicles pay advisory fees to their
investment advisers, which reduces fund assets. In addition, clients of Bahl & Gaynor are billed
advisory fees as outlined in their advisory agreements. As a result, clients investing in mutual
funds, index funds, or ETFs may bear two levels of advisory fees on the portion of their
portfolios invested in such vehicles.
Wrap Fee Programs and Separately Managed Account Fees: B&G is not a sponsor of a wrap
fee program. However, some clients may participate in a wrap fee program sponsored by their
custodian. Clients participating in separately managed account programs may incur additional
program fees beyond the advisory fee charged by B&G. Such fees may include the investment
advisory fees of independent advisers, which may be charged as part of a wrap fee
arrangement.
In a wrap fee arrangement, clients pay a single fee covering advisory, brokerage, and custodial
services. Portfolio transactions in these accounts may be executed without commission
charges. In evaluating such arrangements, clients should consider that, depending on the level
of the wrap fee, the volume of portfolio activity, and other factors, the wrap fee may be higher
or lower than the aggregate cost of obtaining these services separately.
Retirement Account(s): B&G provides investment advice regarding retirement plan account
or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable.
Because the way we earn compensation may create conflicts of interests, we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours.
12
Under this rule, we must:
•
•
•
•
•
•
Meet a professional standard of care when making investment recommendations
(prudent advice);
Not putting our financial interests ahead of yours (loyal advice);
Avoid misleading statements regarding conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that advice is in your best interest;
Charge no more than a reasonable amount for services; and
Provide basic information about conflicts of interest.
Additional Fees and Expenses: In addition to advisory fees, clients are responsible for fees
and expenses charged by custodians and broker-dealers, including commissions and other
trade related charges. See Item 12 ("Brokerage Practices") of this Form ADV for additional
information.
Advisory Fees in General: Clients should be aware that similar advisory services may be
available from other registered investment advisers at similar or lower fees.
Item 6 Performance-Based Fees and Side-By-Side Management
B&G does not charge performance-based fees.
Item 7 Types of Clients
B&G provides advisory services for the following types of clients:
Individuals (other than high-net-worth individuals)
High-net-worth individuals
Pension and profit-sharing plans (other than plan participants)
Charitable organizations
Corporations and other businesses entities not listed above.
State and municipal government entities
Investment companies
Insurance companies
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
8. a. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
The B&G equity investment strategies focus on high-quality dividend-growth companies. We
are long-term investors, which it defines as a two-to-five-year horizon, and generally maintains
low portfolio turnover. B&G believes that high-quality companies generate consistent earnings
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growth, maintain manageable debt levels, pay and grow dividends, and are leaders in their
respective markets.
B&G’s portfolio managers/analysts (the Investment Committee) screen equities based on these
fundamental characteristics. They apply thorough fundamental analysis and use a combination
of qualitative and quantitative factors to identify companies that best align with our investment
philosophy. The Investment Committee decides which securities are included in the model
portfolios, while individual portfolio managers construct client accounts according to each
client’s specific goals and objectives around B&G’s core dividend growth philosophy.
While B&G primarily focuses on equity investments, we also manage fixed income investments
when appropriate for a client’s goals or circumstances. Fixed income holdings are typically
included in client portfolios to meet income needs, manage risk, or address liquidity
preferences.
We do not offer fixed income as a separate, standalone investment strategy. Instead, we
incorporate fixed income securities—such as government, corporate, or municipal bonds—
into portfolios when a client requests them or when doing so aligns with their investment
objectives.
The Bahl & Gaynor Income Growth ETF (BGIG), Bahl & Gaynor Small/Mid Cap Income Growth
ETF (SMIG), Bahl & Gaynor Dividend ETF (BGDV), and Bahl & Gaynor Small Cap Dividend ETF
(SCDV) offer potential benefits such as. increased tax efficiency and diversified exposure to
large-cap (BGIG,BGDV) and small/mid-cap (SMIG, SCDV) companies with a relatively small
minimum investment. In certain cases, these benefits may outweigh the added costs when
B&G’s investment management fees are lower than the ETF management fees for the same
strategy.
Clients should carefully weigh the potential costs and benefits of investing in Bahl & Gaynor
ETFs compared to other options. If Bahl & Gaynor ETFs are included in a portfolio, B&G takes
steps to avoid duplicate charges on those assets. Bahl & Gaynor ETFs may also provide a way
for smaller accounts that do not meet SMA minimums to gain diversified exposure.
In cases where client account includes ERISA plan assets or assets of an IRA or other account
subject to Section 4975 of the Internal Revenue Code, Bahl & Gaynor complies with all
applicable requirements of Prohibited Transaction Exemption 77-4.
From time to time, Bahl & Gaynor may also recommend investments in Alternative Funds. Such
investments are made only when the client is an Accredited Investor or Qualified Purchaser,
and considered to be financially sophisticated, capable of evaluating risks, and able to bear the
potential illiquidity and loss of the entire investment. These investments require the client’s
written approval.
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8. b. RISK OF LOSS
Investing in stocks or bonds has risk – Markets can experience significant declines, and
individual stocks can decline due to the company-specific events such as failure to meet
investor expectations. Bond investments carry risks related to interest rate fluctuations,
specific credit deterioration, or default. Any of the above factors can lead to a loss of value.
ETF Risks - The risks of owning an exchange-traded fund (ETF) generally reflect the risks of
the underlying securities held by the ETF. Clients also bear a pro rata share of ETF’s operating
expenses. ETF performance is subject to market risk, including possible loss of principal. ETF
prices fluctuate with the prices of their underlying securities and may diverge from the strategy
of index they track. ETFs are also subject to trading risks, such as loss of cost efficiency if
traded actively, or liquidity risk if there is a wide bid-ask spread and low trading volume. The
price of an ETF purchased or sold at a given time of day may differ from the price at another
time on the same day.
Mutual Fund Risks - The risks of owning a mutual fund generally reflect the risks of the
securities the fund holds. Clients also bear a pro rata share of the fund’s operating expenses.
Mutual fund performance is subject to market risk, including possible loss of principal. The price
of a mutual fund is set once daily; therefore, a mutual fund purchased at one point in the day will
typically have the same price as a purchase later that same day.
Certain mutual funds may also invest in private operating or growth companies or real estate
and may be structured as closed-end interval funds. These funds can bear a high degree of
risk, may use leverage, and can be volatile and speculative. Investors could lose all or a
substantial portion of their investment. Interval funds are less liquid than standard mutual funds,
as they usually allow repurchases only quarterly (or at other limited intervals) and may restrict
the dollar amount that can be liquidated.
Alternative Investments - Alternative investments may be volatile, concentrated, and/or
illiquid. Investors could lose all or part of their investment. These investments often carry higher
risks and are recommended only as a portion of a client’s overall portfolio.
Cybersecurity and Business Continuity Risk – B&G maintains a Business Continuity Plan
(BCP) and Disaster Recovery Plan (DRP) to address potential Significant Business Disruptions
(SBDs). B&G’s policy is to safeguard employees, protect client interests, conduct rapid
operational assessments, and resume operations as quickly as possible. If B&G is unable to
continue business, clients will be assured of prompt access to their funds and securities.
The DRP and BCP outline the firm’s mission-critical systems and procedures necessary to
safeguard operations and restore functionality following natural or man-made disruptions.
These policies are designed to minimize downtime by maintaining resources, personnel, and
equipment to continue critical business functions.
Artificial Intelligence (AI) Risk - Recent technological advances in generative AI and machine
learning technology (collectively, “Artificial Intelligence (AI)”) pose risks to B&G and its clients.
15
AI is a branch of computer science focused on creating systems capable of performing tasks
that typically require human intelligence; this includes, among other things, methods for
analyzing, modeling, and understanding language, as well as developing algorithms that can
learn to perform various tasks. B&G and the companies in which clients invest could be further
exposed to the risks of AI if third-party service providers or any counterparties, whether or not
known to B&G, also use AI in their business activities. B&G cannot control third-party
operations, product development, or service provisions.
AI is generally highly reliant on the collection and analysis of large amounts of data, and it is not
possible or practicable to incorporate all relevant data into the model that AI utilizes to operate.
Certain data in such models will inevitably contain a degree of inaccuracy and error —
potentially materially so — and could otherwise be inadequate or flawed, which would be likely
to degrade the effectiveness of AI. To the extent that B&G or the companies in which clients
invest are exposed to the risks of AI, any such inaccuracies or errors could have adverse
impacts on a client’s performance.
Natural & Unavoidable Events Risk - Global markets are interconnected, and natural disasters
(e.g., hurricanes, floods, earthquakes, wildfires), geopolitical events (e.g., war, terrorism, civil
unrest), and public health crises can cause short-term market volatility and long-term
economic disruption. Clients may have exposure to markets affected by such events, which
could result in material losses.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of our advisory business or the integrity of our management.
B&G and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
B&G and its related persons are not engaged in other financial industry activities and have no
other industry affiliations.
From time to time a broker, dealer or custodian may pay in full or in part for educational
conferences and events; consulting related to technology, compliance, legal, or business
needs; publications and conferences on practice management and business succession;
access to employee benefits providers, human capital consultants, and insurance providers; or
marketing consulting and support. These benefits do not obligate B&G to recommend, request,
or require the use of any such broker, dealer, or custodian.
16
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
11. a. CODE OF ETHICS
The Code of Ethics is based on the principle that B&G owes a fiduciary duty to its clients.
Accordingly, employees must avoid activities, interests and relationships that conflict (or
appear to conflict) with the best interests of clients. At all times, B&G must:
•
•
•
•
•
Place client interests ahead of B&G’s – As a fiduciary, B&G must serve in its clients’
best interests. Employees may not benefit at the expense of advisory clients. This
principle is particularly relevant when employees make personal investments in
securities also traded for clients.
Engage in personal investing consistent with the Code of Ethics – Employees must
review and comply with B&G’s Personal Securities Transaction and Insider Trading
Policies.
Avoid misuse of position – Employees must not accept investment opportunities, gifts
or other gratuities from individuals seeking to conduct business with B&G or on behalf
of an advisory client.
Accept only reasonable compensation - B&G believes that fees for its services should
be reasonable and appropriate for the level of service provided. Fee structures are
detailed in Form ADV Part 2A.
Comply fully with the Federal Securities Laws – Employees must follow the standards
set forth in Rule 204A-1 under the Advisers Act.
A copy of our Code of Ethics is available to clients and prospective clients upon request. To
request a copy, please email info@bahl-gaynor.com, or call 513-287-6100.
11. b. PERSONAL TRADING
Employees of B&G are permitted to buy and sell securities for their personal accounts. To
address potential conflicts of interest, our Code of Ethics requires that employees:
1)
2)
3)
pre-clear certain personal securities transactions,
report personal securities transactions on at least a quarterly basis, and
provide B&G with a detailed summary of specific holdings at the start of employment
and annually thereafter, including holdings over which they have a direct or indirect
beneficial interest.
Potential conflicts may arise when employees trade in the same securities that B&G is buying,
selling, or holding on behalf of clients, as this could result in employees receiving a more
favorable price than clients trading the same security.
To mitigate these conflicts, B&G has adopted a personal trading policy. A “restricted list” of
securities is maintained to notify employees of securities they are prohibited from trading in
their own accounts. Generally, employees must refrain from trading these securities for a
17
specified period, typically one week after B&G has executed a similar transaction for client
accounts.
To further enhance compliance oversight, B&G utilizes Compliance Alpha, a compliance
technology platform that automates and improves compliance monitoring. Compliance Alpha
assists the compliance team in tracking adherence to regulatory and internal standards,
providing real-time data insights, and supporting timely risk assessments.
Our compliance staff monitors employee trading activity against the restricted list through
quarterly transaction reports. Any policy violations are addressed by the Chief Compliance
Officer in accordance with the Code of Ethics.
11. c. TRADING OF BAHL & GAYNOR PROPRIETARY ACCOUNTS
Bahl & Gaynor’s firm accounts are intended to invest in Bahl & Gaynor-advised ETFs over time,
with the objective of building long-term investment from the firm's balance sheet. These
investments are intended to align the interests of B&G, its employees, and its clients.
Bahl & Gaynor may invest in its ETFs through market transactions and conduct such trading
activity with consideration for potential market impact. When transacting in the advised ETFs,
Bahl & Gaynor may consider various factors including daily volume.
We recognize that the volume and timing of its transactions do not necessarily reflect the
liquidity of the advised ETFs, which is driven by the liquidity of their underlying holdings.
11. d. SERVING AS OFFICER, TRUSTEE AND/OR DIRECTORS OF OUTSIDE ORGANIZATIONS
Employees may, under certain circumstances, be granted permission to serve as directors,
trustees or officers of outside organizations. Such organizations may include public or private
corporations, partnerships, charitable foundations, and other not-for-profit institutions.
Employees may also receive compensation for these activities.
Service with organizations outside of B&G can raise regulatory concerns, including conflicts of
interests and the risk of access to material non-public information.
As an outside board member or officer, an employee may come into possession of material
non-public information about the outside company, or other public companies. It is critical that
an appropriate information barrier be maintained between B&G and the outside organization,
and that the employee does not communicate such information to other B&G employees in
violation of that barrier.
Additionally, if Bahl & Gaynor has, or seeks to establish, a business relationship with the outside
organization, the employee must not participate in the decision to retain or hire Bahl & Gaynor.
18
11. e. RELATED PERSONS AT BROKERS AND CUSTODIANS
Relatives of B&G employees may work for financial entities with which B&G conducts business.
Relationships between the employee, the related party, and the financial entity are reviewed
and evaluated for potential conflicts of interest.
11. f. POLITICAL CONTRIBUTIONS
Rule 206(4)-5 under the Advisers Act (“Pay-to-Play Rule”) requires any covered associate that
makes political contributions to an “official” of a state or local “government entity” to comply
with the following restrictions:
1)
2)
3)
4)
Impose a two-year ban on the adviser receiving compensation for advisory services to
a government entity following certain contributions by a covered associate;
Prohibits an adviser and its covered associates soliciting or coordinating contributions
to officials or payments to certain state or local political parties;
Prohibits an adviser from paying a third-party solicitor to solicit a government client for
the adviser’s advisory services unless the third party is a “regulated person,” such as an
SEC-registered broker-dealer or investment adviser subject to the rule; and
Extends to investment advisers that manage assets of a government entity indirectly
through covered investment pools, including hedge funds, private equity funds, venture
capital funds, collective trust funds, and registered investment companies offered as
options in government-related plans such as 529, 403(b), and 457 plans.
The portfolio management team of B&G is permitted to make political contributions up to the
de minimis limits: up to $350 per election to a candidate for whom the contributor is entitled to
vote, and up to $150 per election to a candidate for whom the contributor is not entitled to vote.
B&G officers must report political contributions quarterly using the firm’s Political Contribution
Form. Reports must include the date of contribution, the recipient, whether the contributor was
entitled to vote for the candidate, and the contribution amount.
Any contribution exceeding the de minimis limit must be pre-cleared. The firm also conducts a
two-year lookback review for new officers to ensure compliance with the Pay-to-Play Rule
Item 12 Brokerage Practices
12. a. BEST EXECUTION
B&G’s principal objective in selecting brokers and placing client trades is to obtain best
execution. Best execution involves evaluating multiple factors, including:
1)
2)
3)
4)
Price received or paid for the security
Brokerage costs
Timeliness of the transaction
Ability to transact smoothly from order placement through settlement
19
5)
6)
Recordkeeping
Custody services provided
B&G maintains a Best Execution Committee, which meets semi-annually to review brokers. We
also engage with an independent provider for quantitative best execution analysis.
Clients that direct brokerage reduce our ability to seek best execution and negotiate
commissions and have limited ability to negotiate commissions and monitor for best execution.
Trading away from a custodian broker typically results in additional charges to the client.
In some programs, the sponsor or overlay manager, not B&G, is responsible for placing trades.
Because these sponsors or managers execute trades on their own schedule, the timing and
prices they receive may differ from those obtained by B&G’s discretionary clients. As a result,
the sponsor’s trades may be executed at higher or lower prices depending on market
conditions. B&G does not control when or how these trades occur and cannot influence their
market impact.
In model-based programs, the sponsor or overlay manager generally makes investment
decisions and handles many of the day-to-day functions that B&G would otherwise perform in
a discretionary account. Depending on the program’s structure, B&G may not have a direct
advisory relationship with the individual clients in the program. In these cases, this brochure is
provided for informational purposes only.
Performance results for B&G’s discretionary accounts may differ from the results experienced
by clients in model-based programs. B&G is not responsible for the services or execution
practices of the program sponsor or overlay manager.
12. b. BLOCK TRADES
12.b. Block Trades
We generally aggregate client transactions into block trades when we believe doing so is
advantageous in seeking favorable execution and pricing. When trades are aggregated,
participating accounts typically receive the same average price, and any partial fills are
allocated on a pro rata basis.
In certain circumstances, including when transactions are of a de minimis size, we may elect to
execute trades on an individual account basis rather than through a block trade. This
determination may be made when aggregation would result in the assessment of custodial
transaction charges that would not otherwise apply. While this approach may limit or avoid such
charges, accounts traded on a non-aggregated basis may not receive the potential pricing or
execution benefits associated with aggregated trading.
12. c. SOFT DOLLARS
20
B&G may use non-directed client commission dollars to obtain investment-related research
and brokerage services, a practice commonly referred to as “soft dollars.”
This research may include, but is not limited to, written company and industry reports,
economic data, historical charts and graphs, meetings with company management, and access
to industry conferences hosted by brokerage firms. Brokerage services may include security
information such as price quotes, dividend data, stock split information, news updates,
exchange access, daily and monthly pricing of securities, price charts, graphs, and other
technical analyses of stocks and bonds.
The use of soft dollars creates a conflict of interest. Only non-directed, commission-paying
equity trades executed through participating brokers generate soft-dollar benefits. All clients
may benefit from the research and services obtained. Although B&G seeks to negotiate
competitive commission rates with brokers, clients may pay higher commissions than they
might otherwise pay for execution-only trades. In addition, brokers that provide soft dollar
benefits may be favored over others. Some trades are placed directly with brokers providing
research, while others are executed through third-party brokers who remit payments to the
service providers.
B&G conducts its soft dollar practices in accordance with Section 28(e) of the Securities
Exchange Act of 1934, which provides a safe harbor for advisers that use client commission
dollars to obtain research and brokerage services that are eligible under the statute.
12.d. TRADE ORDER ROTATION
B&G’s fully discretionary, non-directed brokerage accounts, and directed accounts
participating in a randomized rotation program are included within a single trade rotation along
with all Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA) programs,
traded in a snake-like order.
Model strategies are also available through certain SMA and UMA programs offered by other
investment advisory firms. In these cases, Bahl & Gaynor does not work directly with the
individual client or execute trades; instead, the firm communicates model trades to the
SMA/UMA platform partners.
•
•
•
The Trade Order Rotation Process
When a model trade is scheduled, trades are entered using a single rotation that
includes Bahl & Gaynor’s fully discretionary accounts and all SMA/UMA platform
relationships.
Within the rotation, all groups are traded in snake order (i.e., trade first today, trade last
on the next trade).
All allocations are made by close of business on trade date. If an order is partially filled,
the allocation is made on a pro rata basis so that each account in the order receives the
same percentage of the trade.
21
Trades for Bahl & Gaynor-advised ETFs follow an independent process determined by the ETF
Basket Committee, based on factors such as capital market conditions, ETF market liquidity,
and other investment considerations.
12. e. CROSS TRANSACTIONS (AGENCY)
An agency cross trade is a transaction between two clients’ accounts managed by the same
investment adviser. It is B&G’s policy to engage in agency cross transactions only when
necessary and only when such transactions are in the best interests of both clients. All agency
cross trades are reported to the firm’s Chief Compliance Officer. B&G does not receive any
compensation for these trades other than its normal advisory fee.
B&G does not engage in principle cross trades.
Item 13 Review of Accounts
13. a. REVIEWS
The underlying securities in client accounts are continually monitored, and the compliance and
portfolio management teams conduct regular reviews. Each account is assessed against the
client’s stated investment objectives and guidelines. Portfolio managers may also conduct
more frequent reviews based on client circumstances.
Clients are encouraged to compare custodial reports with Bahl & Gaynor reports to ensure
consistency.
13. b. REPORTS
In addition to the monthly or quarterly statements and transaction confirmations clients receive
from their custodian, B&G will provide monthly, quarterly, or annual reports upon client request.
These reports summarize the account value, securities held (with market value of each),
estimated annual income, and cost basis information, if available. Reports may be delivered by
mail or online, depending on client preference.
Reports on individual securities may include the number of shares, price, total market value,
dividend information, estimated annual income, and cost basis (if available). B&G is not
responsible for the accuracy of cost basis information provided by clients.
Item 14 Client Referrals and Other Compensation
B&G does not receive any economic benefits, including sales awards, referral fees, or other
compensation, from third parties in connection with providing advisory services to clients.
Additionally, B&G does not compensate any third parties for client referrals.
22
Item 15 Custody
B&G has custody of client assets solely because it is authorized to debit management fees
directly from client individually managed accounts. This limited form of custody qualifies for
the “fee deduction” exemption and does not require an annual surprise custody examination.
As disclosed in Item 5 (“Fees and Compensation”) of this Brochure, Bahl & Gaynor may directly
debit advisory fees from client custodial accounts if authorized by the client.
As part of this billing process, the client's qualified custodian is notified of the amount of the fee
to be deducted from the account. Clients should receive regular (monthly or quarterly) account
statements from the broker-dealer, bank or other financial services firm that serves as qualified
custodian, and clients should carefully review those statements.
Because the custodian does not calculate the fee, it is important for clients to carefully review
custodial statements to verify the accuracy of fee calculations and other account activity.
Clients should contact B&G promptly if they believe there may be an error.
In addition to the periodic custodial statements, B&G may provide account reports monthly,
quarterly, or annually, either by mail or electronically, upon client request. Clients who receive
additional reports from B&G are urged to compare these reports to the account statements
they receive from the qualified custodian.
Item 16 Investment Discretion
Clients with individually managed account may engage B&G to provide discretionary asset
management services, which allows B&G to place trades in client account without obtaining
prior approval for each transaction. Clients grant discretionary authority by signing a
discretionary management agreement with B&G. This authority may be limited if clients provide
specific written instructions.
For clients with non-discretionary agreements, B&G obtains the client’s consent, either orally
or in writing, before executing any recommended investment transactions in their accounts.
For Separately Managed Accounts (SMAs) offered through wrap fee programs, B&G is
appointed as an investment adviser through documentation managed by the program sponsor.
With assistance from the sponsor, clients may select B&G to manage their account (or a portion
of it) in a specific strategy.
B&G provides investment management services based on information the sponsor provides
about each client’s investment objectives and restrictions. B&G is generally available for
consultations when reasonably requested by clients or sponsors.
Clients should consult their own financial, legal, and tax professionals—both when they first
select an investment strategy and on an ongoing basis. When clients work with outside financial
23
advisors, B&G typically relies on the information or directions that those advisors communicate
on the client’s behalf.
B&G’s discretionary authority over any account is subject to the directions, guidelines, and
limitations established by the client—and, in the case of SMA accounts, by the program
sponsor. B&G will follow reasonable instructions and investment guidelines, but the firm may
decline or terminate accounts that impose restrictions that are overly burdensome or
materially inconsistent with its investment approach (for example, restrictions affecting a
significant portion of the account). See Item 4 for more details.
In addition, B&G may provide advisory services on a non-discretionary or model portfolio basis.
Item 17 Voting Client Securities
Proxy voting is an important client right, and B&G takes reasonable care to exercise these rights
properly and in a timely manner. When B&G has discretionary authority to vote client proxies, it
votes in the best interests of its clients, following B&G’s proxy policies and procedures.
B&G does not vote proxies in-house. Instead, B&G has engaged Broadridge’s ProxyEdge
platform to facilitate proxy voting and maintain records of all proxy activities for individual
managed accounts. This open-architecture platform allows B&G to select from multiple proxy
advisory firms for voting recommendations. B&G has chosen Glass Lewis as its advisory firm.
Glass Lewis evaluates issuers based on factors such as the reputation, experience, and
competence of company management and boards of directors.
B&G’s complete proxy voting policy and procedures, as well as those of its proxy voting service
providers, are maintained in writing and are available for client review upon request.
Additionally, proxy voting records are also available to clients upon request. Clients may
contact B&G at the phone number provided in this Brochure if they have questions or wish to
review these documents.
In addition to proxy voting, B&G has engaged Broadridge to manage class action claim filings
for individually managed accounts. Occasionally, securities held in client accounts may be the
subject of class action lawsuits.
Broadridge identifies eligible cases, files Proof of Claim forms, monitors claim status, and
facilitates the distribution of settlement proceeds in accordance with SEC guidelines. For these
services, Broadridge collects a fee equal to 12% of any settlement amount received. This fee
is deducted from the proceeds prior to distribution to the client.
Item 18 Financial Information
B&G has no additional financial circumstances to report.
24
The firm does not require or solicit payment of fees in excess of $1,200 per client, more than
six months in advance of services rendered. Therefore, Bahl & Gaynor is not required to include
a financial statement. Bahl & Gaynor has not been the subject of a bankruptcy petition at any
time during the past ten years.
25
Additional Brochure: BAHL & GAYNOR ADV PART 2B 7/2026 (2026-07-07)
View Document Text
Part 2B of Form ADV: Brochure Supplement
255 East Fifth Street
Suite 2700
Cincinnati, OH 45202
Telephone: 513-287-6100
Email: info@bahl-gaynor.com
Web Address: www.bahl-gaynor.com
7/7/2026
This brochure supplement provides information about investment management personnel of Bahl &
Gaynor LLC that supplements the Bahl & Gaynor Investment Counsel brochure. You should have
received a copy of that brochure. Please contact Bahl & Gaynor if you have not received the Bahl &
Gaynor brochure or if you have any questions about the contents of the supplement.
Bahl & Gaynor LLC is a registered investment adviser under the U.S. Investment Adviser Act of 1940, as
amended. Registration of an Investment Adviser does not imply any level of skill or training. The oral
and written communications of an Adviser provide you with information about which you determine to
hire or retain an Adviser.
Additional information about Bahl & Gaynor LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. Our firm's CRD number is 106139.
Full Legal Name
Born 1961
CHARLES A. PETTENGILL
Education
Colgate University; BA, Economics; 1984
University of Chicago; MBA; Finance; 1986
Business Experience
Bahl & Gaynor LLC; Director; from 1/2026 to current
Bahl & Gaynor LLC; Chairman of the Board; from 4/2022 to 12/2025
Bahl & Gaynor LLC; Vice President, Senior Wealth Advisor; from 5/1/1997 to 4/2022
Designation
Charles A. Pettengill has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/1996
1 Please see Minimum Qualifications Required below
Disciplinary Information
Charles A. Pettengill has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Charles A. Pettengill is not engaged in any other investment-related activities.
2. Charles A. Pettengill does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Charles A. Pettengill is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Charles A. Pettengill does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
2
Full Legal Name
Born 1956
ELEANOR K. MOFFAT
Education
Princeton University; AB, History; 1978
John Hopkins University; MAS; Administrative Science; 1983
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 1/1/1999 to current
Designation
Eleanor K. Moffat has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/1988
1 Please see Minimum Qualifications Required below
Disciplinary Information
Eleanor K. Moffat has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Eleanor K. Moffat is not engaged in any other investment related activities.
2. Eleanor K. Moffat does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Eleanor K. Moffat is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Eleanor K. Moffat does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
3
Full Legal Name
Born 1962
SCOTT D. RODES
Education
Vanderbilt University; BE, Mechanical Engineering; 1985
Xavier University; MBA; Business; 1987
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 6/1/2001 to current
Designation
Scott D. Rodes has earned the following designation and is in good standing with the granting
authority.
CFA®; Institute of Chartered Financial Analyst; 9/1993
1 Please see Minimum Qualifications Required below
Disciplinary Information
Scott D. Rodes has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Scott D. Rodes is not engaged in any other investment-related activities.
2. Scott D. Rodes does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Scott D. Rodes is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Scott D. Rodes does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
4
Full Legal Name
Born 1966
EDWARD A. WOODS
Education
Wittenberg University; BA, Business Administration; 1989
University of Cincinnati, MBA, Finance; 1996
Business Experience
Bahl & Gaynor LLC; Director, Senior Wealth Advisor; from 9/1/2004 to current
Designation
Edward A. Woods has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/1996
1 Please see Minimum Qualifications Required below
Disciplinary Information
Edward A. Woods has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Edward A. Woods is not engaged in any other investment-related activities.
2. Edward A. Woods does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Edward A. Woods is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Edward A. Woods does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
5
Full Legal Name
Born
1960
JOHN B. SCHMITZ
Education
University of Cincinnati, BA, Finance and Real Estate; 1982
Business Experience
Bahl & Gaynor LLC; Director, Portfolio Manager; from 12/1/2005 to current
Designation
John B. Schmitz has earned the following designation and is in good standing with the granting
authority.
CFA®; Institute of Chartered Financial Analyst; 9/1992
1 Please see Minimum Qualifications Required below
Disciplinary Information
John B. Schmitz has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. John B. Schmitz is not engaged in any other investment-related activities.
2. John B. Schmitz does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. John B. Schmitz is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
John B. Schmitz does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
6
Full Legal Name
Born
1968
ELLIS D. HUMMEL
Education
Skidmore College, BA, Government; 1990
Business Experience
Bahl & Gaynor LLC; Director, Senior Wealth Advisor; from 2/1/2008 to current
Designation
Ellis D. Hummel has earned the following designation and is in good standing with the granting
authority.
CFP®; College of Financial Planning™; 6/2002
2Please see Minimum Qualifications Required below
Disciplinary Information
Ellis D. Hummel has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Ellis D. Hummel is not engaged in any other investment-related activities.
2. Ellis D. Hummel does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Ellis D. Hummel is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Ellis D. Hummel does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
7
Full Legal Name
Born
1967
STEPHANIE S. THOMAS
Education
Wittenberg University, BA, Economics; 1989
University of Notre Dame, MBA 1996
Business Experience
Bahl & Gaynor LLC; Institutional Client Managing Director, Portfolio Manager;
from 7/2/2012 to current
Designation
Stephanie S. Thomas has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/2001
1 Please see Minimum Qualifications Required below
Disciplinary Information
Stephane S. Thomas has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Stephane S. Thomas is not engaged in any other investment-related activities.
2. Stephane S. Thomas does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Stephane S. Thomas is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Stephane S. Thomas does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
8
Full Legal Name
Born
1979
W. JEFF BAHL
Education
Washington & Lee University, BSBA, Commerce; 2002
Business Experience
Bahl & Gaynor LLC; Chairman of the Board, Director; from 1/2026 to current
Bahl & Gaynor LLC; Director, Senior Wealth Advisor; from 5/1/2014 to 12/2025
Disciplinary Information
W. Jeff Bahl has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. W. Jeff Bahl is not engaged in any other investment-related activities.
2. W. Jeff Bahl does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. W. Jeff Bahl is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
W. Jeff Bahl does not receive any economic benefit from a non-advisory client for the provision
of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
9
Full Legal Name
Born
1960
CHRISTOPHER M. ROWANE
Education
Gannon University, BSBA, Finance; 1983
Gannon University, MBA, Finance; 1988
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 5/1/2014 to current
Designation
Christopher M. Rowane has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/1998
1 Please see Minimum Qualifications Required below
Disciplinary Information
Christopher M. Rowane has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Christopher M. Rowane is not engaged in any other investment-related activities.
2. Christopher M. Rowane does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Christopher M. Rowane is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Christopher M. Rowane does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
10
Full Legal Name
Born
1987
NICHOLAS W. PUNCER
Education
University of Cincinnati; BBA, Finance and Business Economics; 2010
Business Experience
Bahl & Gaynor LLC; Institutional Product Managing Director, Portfolio Manager, from 5/1/2014
to current; Analyst, from 2010 to April 2014
Designation
Nicholas W. Puncer has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/2014
1 Please see Minimum Qualifications Required below
CFP®; College of Financial Planning™; 6/2014
2Please see Minimum Qualifications Required below
Disciplinary Information
Nicholas W. Puncer has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Nicholas W. Puncer is not engaged in any other investment-related activities.
2. Nicholas W. Puncer does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Nicholas W. Puncer is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Nicholas W. Puncer does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
11
Full Legal Name
Born
1970
CHRISTOPHER J. HEEKIN
Education
Duke University, BA, Economics; 1992
Darden School at University of Virginia, MBA, 1999
Business Experience
Bahl & Gaynor LLC; Wealth Management Managing Director, Senior Wealth
Advisor; from 10/17/2016 to current
Designation
Christopher J. Heekin has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 7/2017
2Please see Minimum Qualifications Required below
CAP®; Chartered Advisor in Philanthropy; 2/2022
6Please see Minimum Qualifications Required below
Disciplinary Information
Christopher J. Heekin has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Christopher J. Heekin is not engaged in any other investment-related activities.
2. Christopher J. Heekin does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Christopher J. Heekin is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Christopher J. Heekin does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
12
Full Legal Name
Born
1981
STEVEN N. BROWN
Education
University of Cincinnati; BA, Finance; 2004
Business Experience
Bahl & Gaynor LLC; Financial Planning Specialist; from 1/8/2018 to current
Huntington National Bank; Vice President and Wealth Advisor; from August 2011 to January
2018
Designation
Steven N. Brown has earned the following designation and is in good standing with the granting
authority.
CFP®; College of Financial Planning™; 3/2008
2Please see Minimum Qualifications Required below
Disciplinary Information
Steven N. Brown has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Steven N. Brown is not engaged in any other investment-related activities.
2. Steven N. Brown does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Steven N. Brown is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Steven N. Brown does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
13
Full Legal Name
Born
1988
SAMUEL L. KOOPMAN
Education
Xavier University, BSBA, Finance; 2010
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 7/1/2018 to current; Wealth Advisor Analyst;
from 6/15/2015 to 6/30/2018
United States Army, Company Executive Officer; from 1/1/2014 to 6/1/2015; Brigade Medical
Operations Officer; from 1/1/2013 – 12/31/2014
Designation
Samuel L. Koopman has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 5/2017
2Please see Minimum Qualifications Required below
Disciplinary Information
Samuel L. Koopman has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Samuel L. Koopman is not engaged in any other investment-related activities.
2. Samuel L. Koopman does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Samuel L. Koopman is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Samuel L. Koopman does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
14
Full Legal Name
Born
1991
KEVIN T. GADE
Education
University of Cincinnati; BBA, Finance & Business Economics; 2014
Business Experience
Bahl & Gaynor LLC; Chief Operating Officer & Portfolio Manager, from 4/2022
to current; Portfolio Manager, from 7/17/2018 to 4/2022; Portfolio Analyst, from 9/1/2016 to
7/11/2018
Designation
Kevin T. Gade has earned the following designation and is in good standing with the granting
authority.
CFA®; Institute of Chartered Financial Analyst; 8/2017
1 Please see Minimum Qualifications Required below
CFP®; College of Financial Planning™; 3/2018
2Please see Minimum Qualifications Required below
Disciplinary Information
Kevin T. Gade has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Kevin T. Gade is not engaged in any other investment-related activities.
2. Kevin T. Gade does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Kevin T. Gade is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Kevin T. Gade does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
15
Full Legal Name
Born
1980
KEITH HERBERT RENNEKAMP
Education
The Ohio State University Fisher College of Business BSBA, Finance, 2002
Xavier University Williams College of Business MBA, Finance, 2007
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 5/29/2018 to current
Huntington National Bank; Vice President, Senior Portfolio Manager; from September
2013 to May 2018
Designation
Keith Herbert Rennekamp has earned the following designation and is in good standing with
the granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/2009
1 Please see Minimum Qualifications Required below
CFP®; College of Financial Planning™; 4/2012
2Please see Minimum Qualifications Required below
Disciplinary Information
Keith Herbert Rennekamp has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Keith Herbert Rennekamp is not engaged in any other investment-related activities.
2. Keith Herbert Rennekamp does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
Keith Herbert Rennekamp consults with the CFA Institute that results in
approximately 120 hours of his time in a one-year cycle. The majority of that time is
outside of normal business hours, and Mr. Rennekamp is paid a stipend for his
consultation.
Additional Compensation
Keith Herbert Rennekamp does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
16
Full Legal Name
Born
1969
PETER MICHAEL KWIATKOWSKI
Education
California State University at Long Beach BS, Finance, Real Estate, & Law 1999
Business Experience
Bahl & Gaynor LLC; Chief Investment Officer, Portfolio Manager; from 4/2022
to current; Portfolio Manager; from 1/14/2019 to 4/2022
ClearArc Capital; in multiple positions most recently as Director, Growth &
Income Strategies from 11/2002 to 12/2018
Designation
Peter Michael Kwiatkowski has earned the following designation and is in good standing with
the granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/2002
1 Please see Minimum Qualifications Required below
Disciplinary Information
Peter Michael Kwiatkowski has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
Peter Michael Kwiatkowski is not engaged in any other investment related.
activities.
2. Peter Michael Kwiatkowski does not receive commissions, bonuses or other
compensation for the sale of securities or other investment products.
B. Non-Investment Related Activities
Peter Michael Kwiatkowski is not engaged in any other business or occupation
that provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Peter Michael Kwiatkowski does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
17
Full Legal Name
Born
1983
ROBERT SCOTT GROENKE
Education
University of Michigan, BA, Economics, 2005
University of Chicago, MBA, 2012
Business Experience
Bahl & Gaynor LLC; Chief Executive Officer & President, Portfolio Manager, from
4/2022 to current; Portfolio Manager, from 12/16/2019 to 4/2022
Franklin Templeton; Vice President & Research Analyst, from 2018 to December
2019; Research Analyst; from August 2012 to 2018
Disciplinary Information
Robert Scott Groenke has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Robert Scott Groenke is not engaged in any other investment-related activities.
2. Robert Scott Groenke does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Robert Scott Groenke is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Robert Scott Groenke does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
18
Full Legal Name
Born
1980
MAURA ANNE KELLY
Education
University of Dayton, BSBA, Finance (major) & Accounting (minor), 2002
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 3/30/2020 to current
US Bank; Senior Vice President, Senior Portfolio Manager; from May 2017 to
March 2020
Fifth Third Bank; Vice President, Senior Portfolio Manager; from December 2012
to May 2017
Designation
Maura Anne Kelly has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; Xavier University, 2/2008
2Please see Minimum Qualifications Required below
Disciplinary Information
Maura Anne Kelly has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Maura Anne Kelly is not engaged in any other investment-related activities.
2. Maura Anne Kelly does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Maura Anne Kelly is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Maura Anne Kelly does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
19
Full Legal Name
Born
1976
ANDREW HAGEDORN
Education
University of Kentucky BSBA, Management and Economics, 1998
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 10/4/2021 to current
Huntington National Bank; Senior Vice President & National Portfolio Manager Executive;
from 12/2001 to 9/2021
Disciplinary Information
Andrew Hagedorn has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Andrew Hagedorn is not engaged in any other investment-related activities.
2. Andrew Hagedorn does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Andrew Hagedorn is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Andrew Hagedorn does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
20
Full Legal Name
Born
1993
IAN THOMAS OWENS
Education
University of Cincinnati, BBA, Finance; 2017
Business Experience
Bahl & Gaynor LLC; Associate Portfolio Manager, from 5/2023 to current; Portfolio Analyst,
from 8/14/2017 to 5/2023
Designation
Ian Thomas Owens has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 11/2021
1 Please see Minimum Qualifications Required below
Disciplinary Information
Ian Thomas Owens has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Ian Thomas Owens is not engaged in any other investment-related activities.
2. Ian Thomas Owens does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Ian Thomas Owens is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Ian Thomas Owens does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
21
Full Legal Name
Born
1995
ERIC JAMES ZINS
Education
University of Cincinnati College of Business BBA, Finance; 2018
Business Experience
Bahl & Gaynor LLC; Associate Portfolio Manager, from 5/2023 to current; Portfolio Analyst;
from 8/20/2018 to 5/2023
Designation
Eric James Zins has earned the following designation and is in good standing with the granting
authority.
CFA®; Institute of Chartered Financial Analyst; 2/2021
1 Please see Minimum Qualifications Required below
Disciplinary Information
Eric James Zins has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Eric James Zins is not engaged in any other investment-related activities.
2. Eric James Zins does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Eric James Zins is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Eric James Zins does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
22
Full Legal Name
Born
1997
MATTHEW JOHN CARROLL
Education
Xavier University Williams College of Business BSBA, Finance, 2020
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 8/17/2020 to current
Prior to 8/2022 Matthew John Carroll was a student at Xavier University
Designation
Matthew John Carrol has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 3/2022
2Please see Minimum Qualifications Required below
Disciplinary Information
Matthew John Carroll has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Matthew John Carroll is not engaged in any other investment-related activities.
2. Matthew John Carroll does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Matthew John Carroll is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Matthew John Carroll does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
23
Full Legal Name
Born
1995
KELSEY MARIE FLANNERY
Education
University of Kentucky Gatton College of Business BBA, Finance 2016
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 8/26/2021 to current
Huntington National Bank; Portfolio Manager; from 9/2017 to 8/2021
Designation
Kelsey Marie Flannery has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 8/2022
2Please see Minimum Qualifications Required below
Disciplinary Information
Kelsey Marie Flannery has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Kelsey Marie Flannery is not engaged in any other investment-related activities.
2. Kelsey Marie Flannery does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Kelsey Marie Flannery is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Kelsey Marie Flannery does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
24
Full Legal Name
Born
1990
MICHAEL MURRAY DELPRINCE
Education
Centre College, BA, Economics, 2013
University of Cincinnati, MS, Taxation, 2022
Business Experience
Bahl & Gaynor LLC; Wealth Advisor; from 2/2023 to present; Senior Wealth Management
Analyst; from 2/14/2022 to 2/2023
Nationwide Financial; Territory Manager; from January 2017 to February 2022
Designation
Michael Murray Del Prince has earned the following designation and is in good standing with
the granting authority.
CFP®; College of Financial Planning™; 12/2016
2Please see Minimum Qualifications Required below
CEPA; Certified Exit Planning Advisor; 10/2025
5Please see Minimum Qualifications Required below
Disciplinary Information
Michael Murray DelPrince has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Michael Murray DelPrince is not engaged in any other investment-related activities.
2. Michael Murray DelPrince does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Michael Murray DelPrince is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Michael Murray DelPrince does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
25
Full Legal Name
Born
1974
CHRISTIAN ROBERTS WING
Education
University of Cincinnati BA, Communications 1997
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 2/03/2023 to current
Huntington National Bank; from June 2010 to January 2023
Disciplinary Information
Christian Roberts Wing has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Christian Roberts Wing is not engaged in any other investment related activities.
2. Christian Roberts Wing does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Christian Roberts Wing is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Christian Roberts Wing does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
26
Full Legal Name
Born
1987
GRANT EMERSON COOPER
Education
Miami University, BS, Finance, 2009
University of Cincinnati, MS, Finance, 2015
Business Experience
Bahl & Gaynor LLC; Wealth Advisor; from 10/31/2022 to current
US Bank Private Wealth Management; Portfolio Manager and Vice President;
from May 2018 to October 2023
Johnson Investment Counsel; Portfolio Manager Assistant, from May 2015 to May
2018
Designation
Grant Emerson Cooper has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 9/2019
1 Please see Minimum Qualifications Required below
CFP®; College of Financial Planning™; 3/2020
2Please see Minimum Qualifications Required below
Disciplinary Information
Grant Emerson Cooper has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Grant Emerson Cooper is not engaged in any other investment-related activities.
2. Grant Emerson Cooper does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Grant Emerson Cooper is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Grant Emerson Cooper does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
27
Full Legal Name
Born
1974
MARCIE LIN WRIGHT
Education
Loyola University Chicago, Quinlan School of Business, M.B.A., Business Administration, 2014
Columbia College of Missouri, B.S., Business Administration, 2000
Highland Community College, A.S., Business Administration, 1995
Business Experience
Bahl & Gaynor LLC; Senior Wealth Advisor; from 5/1/24 to current
Fifth Third Bank; Senior Vice President, Managing Director, Private Bank Portfolio
Management, Regional Director of Portfolio Management, Team Lead and Senior Portfolio
Manager; from April 2005 – April 2024
Designation
Marcie Lin Wright has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 7/2008
2Please see Minimum Qualifications Required below
Disciplinary Information
Marcie Lin Wright has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Marcie Lin Wright is not engaged in any other investment-related activities.
2. Marcie Lin Wright does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Marcie Lin Wright is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Marcie Lin Wright does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
28
Full Legal Name
Born
1999
CHRISTOPHER ANTHONY GUY
Education
University of Cincinnati College of Business BBA, Finance, 2022
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 08/15/2022 to current
Prior to 8/2022 Chris Anthony Guy was a student at University of Cincinnati
Designation
Christopher Anthony Guy has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 8/2024
2Please see Minimum Qualifications Required below
Disciplinary Information
Christopher Anthony Guy has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Christopher Anthony Guy is not engaged in any other investment-related activities.
2. Christopher Anthony Guy does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Christopher Anthony Guy is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Christopher Anthony Guy does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
29
Full Legal Name
Born
1994
DERRICK KIHEMBO
Education
The Johns Hopkins University B.S., Economics 2016
Business Experience
Bahl & Gaynor LLC; Associate Portfolio Manager & Senior Trader; from 6/01/2018 to current
Designation
Derrick Kihembo has earned the following designation and is in good standing with the
granting authority.
CFA®; Institute of Chartered Financial Analyst; 2/2022
1Please see Minimum Qualifications Required below
Disciplinary Information
Derrick Kihembo has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Derrick Kihembo is not engaged in any other investment-related activities.
2. Derrick Kihembo does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Derrick Kihembo is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Derrick Kihembo does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
30
Full Legal Name
Born
1999
MARY KATHERINE WALSH
Education
University of Cincinnati, BBA, Finance, 2022
University of Cincinnati, MS, Marketing, 2023
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 08/14/2023 to current
Prior to 8/2023 Mary Katherine Walsh was a student at University of Cincinnati
Designation
Mary Katherine Walsh has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 4/2025
2Please see Minimum Qualifications Required below
Disciplinary Information
Mary Katherine Walsh has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Mary Katherine Walsh is not engaged in any other investment-related activities.
2. Mary Katherine Walsh does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Mary Katherine Walsh is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Mary Katherine Walsh does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
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Full Legal Name
Born
1999
JOHN WILLIAM LANGENDERFER
Education
The Ohio State University, Max M. Fisher College of Business, BBA, Finance, 2023
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 08/14/2023 to current
Prior to 8/2023 John William Langenderfer was a student at The Ohio State University
Designation
John William Langenderfer has earned the following designation and is in good standing with
the granting authority.
CFP®; College of Financial Planning™; 1/2026
2Please see Minimum Qualifications Required below
Disciplinary Information
John William Langenderfer has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
John William Langenderfer is not engaged in any other investment related.
activities.
2. John William Langenderfer does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. John William Langenderfer is not engaged in any other business or occupation
that provides substantial compensation or involves a substantial amount of his
time.
Additional Compensation
John William Langenderfer does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
32
Full Legal Name
Born
2001
WESLEY ANN ALSPAUGH
Education
University of Cincinnati, BBA, Accounting, 2023
University of Cincinnati, Certificate, Business Analytics, 2023
University of Cincinnati, MS, Finance, 2024
Business Experience
Bahl & Gaynor LLC; Wealth Management Analyst; from 01/22/2024 to current
Prior to 01/2024 Wesley Ann Alspaugh was a student at University of Cincinnati
Designation
Wesley Ann Alspaugh has earned the following designation and is in good standing with the
granting authority.
CFP®; College of Financial Planning™; 5/2025
2Please see Minimum Qualifications Required below
Disciplinary Information
Wesley Ann Alspaugh has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Wesley Ann Alspaugh is not engaged in any other investment-related activities.
2. Wesley Ann Alspaugh does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Wesley Ann Alspaugh is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Wesley Ann Alspaugh does not receive any economic benefit from a non-advisory client for
the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
33
Full Legal Name
Born
1983
KRISTEN ELIZABETH ANKENBAUER
Education
Bowling Green State University, B.A., Economics, Political Science, 2005
Business Experience
Bahl & Gaynor LLC; Senior Portfolio Manager; 1/2025 to current
U.S. Bank Private Wealth Management: Senior VP, Private Wealth Advisor & Consultant from
5/2017 to 12/2024
Designation
Kristen Elizabeth Ankenbauer has earned the following designation and is in good standing
with the granting authority.
CFP®; College of Financial Planning™; 7/2017
2Please see Minimum Qualifications Required below
Disciplinary Information
Kristen Elizabeth Ankenbauer has no reportable disciplinary history.
Other Business Activities
A. Investment Related Activities
1. Kristen Elizabeth Ankenbauer is not engaged in any other investment-related activities.
2. Kristen Elizabeth Ankenbauer does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non-Investment Related Activities
1. Kristen Elizabeth Ankenbauer is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time.
Additional Compensation
Kristen Elizabeth Ankenbauer does not receive any economic benefit from a non-advisory
client for the provision of advisory services.
All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an
equity program.
34
Supervision of Firm
Supervisor & Title: Robert S. Groenke, Chief Executive Officer& President
Phone Number: 513-287-6100
Bahl & Gaynor supervises its investment adviser through the firm’s Compliance Policies and
Procedures Manual. These policies and procedures are designed to comply with the supervision
requirements under Section 203(e)(6) of the Advisers Act. The Chief Compliance Officer oversees their
implementation and can be reached at 513-287-6118.
Robert S. Groenke is responsible for overseeing company and business practices. Jenelle M.
Armstrong, Chief Administrative Officer, manages staff-related matters, while Tita A. Rogers,
4IACCP®, Chief Compliance Officer, oversees the Code of Ethics, Investment Policies, Review
Processes, Conflicts, and Risk Assessments.
Both Mrs. Armstrong and Mrs. Rogers report concerns or risks to Mr. Groenke, who has ultimate
supervisory responsibility for all investment and executive employees.
Above Business Experience is for the most recent 5 years.
1 CFA - Minimum Qualifications Required
The CHARTERED FINANCIAL ANALYST, CFA® charter is a professional designation established in 1962
and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-
hour examinations over two to four years. The three levels of the CFA Program test a wide range of
investment topics, including ethical and professional standards, fixed-income analysis, alternative and
derivative investments, and portfolio management and wealth planning. In addition, CFA charter
holders must have at least four years of acceptable professional experience in the investment
decision-making process and must commit to abide by, and annually reaffirm, their adherence to the
CFA Institute Code of Ethics and Standards of Professional Conduct.
2 CFP - Minimum Qualifications Required
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by
Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other
countries for its (1) high standard of professional education; (2) stringent code of conduct and
standards of practice; and (3) ethical requirements that govern professional engagements with clients.
Currently, more than 62,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
•
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a bachelor’s
degree from a regionally accredited United States college or university (or its equivalent from a
foreign university). CFP Board’s financial planning subject areas include insurance planning and
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•
•
•
risk management, employee benefits planning, investment planning, income tax planning,
retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related experience (or
the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
•
•
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to
CFP Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
4IACCP – Minimum Qualifications Required
INVESTMENT ADVISOR CERTIFIED COMPLIANCE PROFESSIONAL, IACCP® The first industry
designation of its kind, the Investment Adviser Certified Compliance Professional (IACCP®), was
developed by the Center for Compliance Professionals, the education and professional development
division of National Regulatory Services (NRS), a resource closely in tune with the changing complexity
of the financial securities compliance profession and provider of compliance education for over 20
years.
The IACCP® is awarded to knowledgeable, experienced individuals who complete an instructor-led
program of face-to-face and online study, pass a certifying examination, and meet work experience,
ethics and continuing education requirements. The designation signifies knowledge of investment
adviser regulation and compliance best practice, and adherence to national recognized professional
standards and ethical leadership.
Exhaustive certification and course development, together with expert instructors and facilitators from
the compliance, legal, regulatory, industry, and academic sectors, help ensure that individuals earning
the IACCP® designation have been trained, tested and certified to meet high industry professional
standards.
IACCP® is a certification owned by the Investment Adviser Compliance Certificate Program®. This
certification is awarded to individuals who successfully complete the program's initial and ongoing
certification requirements.
5CEPA – Minimum Qualifications Required
CERTIFIED EXIT PLANNING ADVISOR, CEPA is issued by the Exit Planning Institute. The CEPA
credential requires completion of a five-day executive-level training program and passage of a
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comprehensive examination. To maintain the designation, CEPAs must complete 40 hours of
continuing education every three years, adhere to the EPI Code of Ethics, and maintain active
membership in the Exit Planning Institute.
6CAP® – Minimum Qualifications Required
The CHARTERED ADVISOR IN PHILANTHROPY, CAP® designation is awarded by The American College
of Financial Services. To earn this designation, an individual must complete three graduate-level
courses focused on philanthropic planning, charitable giving strategies, and gift planning in a nonprofit
context, each with quizzes and a proctored final exam. Candidates must also have at least three years
of full-time, relevant business experience within the five years preceding certification, which may
include work in financial services, nonprofit organizations, or serving on nonprofit boards. In addition,
designees agree to comply with The American College Code of Ethics and Procedures and participate
in the Professional Recertification Program (PRP) to maintain the designation. Continuing education
requirements include 30 hours every two years for client-facing designees, including one hour of
ethics, and one hour of ethics every two years for non-client-facing designees. The program is
delivered online and is self-paced. Verification of the designation is available through The American
College of Financial Services at https://www.theamericancollege.edu.
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